TEXACO, INC., Plaintiff-Appellant,
v.
UNITED STATES of America, Defendant-Appellee.
SHELL OIL COMPANY, Plaintiff-Appellant,
v.
UNITED STATES of America, Defendant-Appellee.
United States Court of Appeals, Fifth Circuit.https://leagle.com/images/logo.png
August 11, 1980.
Rehearing Denied October 14, 1980.
Attorney(s) appearing for the Case
J. W. Bullion, Emily A. Parker, Dallas, Tex., for plaintiff-appellant in No. 77-2271.
Martha J. Stroud, Asst. U.S. Atty., Dallas, Tex., M. Carr Ferguson, Asst. Atty. Gen., William A. Friedlander, Ann B. Durney, John G. Manning, Crombie J. D. Garrett, Tax Div., Dept. of Justice, Washington, D.C., for defendant-appellee in No. 77-2271.
Charles W. Hall and Gerald W. Haddock, Houston, Tex., for plaintiff-appellant in No. 77-2281.
J. A. Canales, U.S. Atty., Houston, Tex., Crombie J. D. Garrett, Ann Belander Durney, John G. Manning, Attys., M. Carr Ferguson, Asst. Atty. Gen., William Friedlander, Atty., Tax Division, U.S. Dept. of Justice, Washington, D.C., for defendant-appellee No. 77-2281.
Before TJOFLAT and VANCE, Circuit Judges, and ALLGOOD, District Judge.
United States Court of Appeals, Fifth Circuit.
PER CURIAM:
Prior to the enactment of the Tax Reform Act of 1969, corporations engaged in oil and gas exploration could obtain certain tax advantages by assigning carved-out production payments1 to corporations, individuals, or charitable organizations, which, in turn, financed their purchase with borrowed funds secured by the production payment. The IRS takes the position that assignments of carved-out production payments were subject...
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